- GANS Trade Insight
Sustainability requirements are becoming a practical part of international trade. Exporters may now be asked to provide information about emissions, product origin, raw materials, packaging and working conditions before a buyer approves an order.
These requests do not all arise from the same source. Some are created by laws in the destination market, while others come from retailers, distributors, lenders or corporate procurement policies. A requirement may apply directly to the importer but still depend on information supplied by the exporter and its manufacturers.
South African businesses should therefore avoid treating sustainability as a separate marketing exercise. It increasingly affects product development, supplier selection, documentation and market access. The appropriate response is not to create evidence for every possible issue, but to identify which requirements apply to each product and destination.
From voluntary preference to trade requirement
International buyers have long considered factors such as product quality, price and delivery. Sustainability adds further questions about how products are made and what happens throughout the supply chain.
An exporter may be asked to demonstrate:
What emissions, energy, water, waste or packaging impacts are associated with the product?
Can the exporter identify the manufacturer, production location and origin of important materials?
Does the supplier maintain appropriate workplace, safety and ethical-business procedures? These questions may appear in tenders, supplier questionnaires, contracts and product-compliance processes. The requested evidence will vary according to the buyer, industry and destination. A business supplying a low-risk finished product may face relatively simple packaging and supplier-information requests. An exporter of carbon-intensive materials or commodities connected to land use may need substantially more detailed records.
Create a product-to-market requirements map
The first step is to connect each export product with the markets in which it is sold or being considered.
The map can record:
- Product and tariff classification
- Destination country
- Buyer and importer
- Materials or ingredients
- Manufacturing location
- Packaging format
- Existing certifications
- Environmental information
- Traceability records
- Applicable product and sustainability requirements
- Person responsible for maintaining the evidence
This prevents the business from applying one generic sustainability checklist to every product.
The exporter should confirm requirements with the buyer and obtain appropriate regulatory advice where necessary. A rule may apply only to particular tariff codes, business sizes or uses.
The completed map can classify requirements as mandatory, contractually requested or voluntary. Mandatory items should be resolved before the commercial order is confirmed.
Furthermore, the merger provided Company with enhanced buying power through the combined volume benefits from shared suppliers. This advantage led to a reduction in the cost of goods sold (COGS), further contributing to overall cost savings.
Through our diligent efforts, we identified hundreds of millions of dollars in cumulative synergies that Company could capitalize on following the merger. The company has successfully reinvested a significant portion of these savings into strengthening its brands and fostering continued growth and success.
Prepare for carbon-related requirements
The European Union’s Carbon Border Adjustment Mechanism, known as CBAM, entered its definitive regime on 1 January 2026. It currently covers selected goods in cement, iron and steel, aluminium, fertilisers, electricity and hydrogen. European Commission CBAM overview
The legal obligations primarily apply to authorised EU importers or their indirect customs representatives. However, importers may need emissions information from non-EU producers to report the embedded carbon associated with imported goods.
EU importers must submit the first CBAM declaration and surrender the corresponding certificates by 30 September 2027 for covered goods imported during 2026. The rules allow reporting through Commission default values or actual emissions information, subject to the applicable methodology and verification requirements. European Commission CBAM communication
A South African exporter of potentially covered goods should:
- Confirm the tariff classification of the product
- Establish whether that classification falls within CBAM
- Identify the production facility
- Discuss information requirements with the EU importer
- Determine whether actual emissions data will be provided
- Maintain consistent production and supporting records
Exporters outside the current CBAM sectors may still receive carbon-data requests from customers. In those cases, the required method, organisational boundary and reporting period should be agreed before calculations begin.
Strengthen traceability for relevant commodities
The EU Deforestation Regulation applies to products associated with seven commodities: cattle, cocoa, coffee, oil palm, rubber, soya and wood. It also covers relevant products listed in the regulation that contain, have been fed with or have been made using those commodities.
The current implementation dates are:
- 30 December 2026 for large and medium operators
- 30 December 2026 for smaller operators already covered by the previous EU Timber Regulation
- 30 June 2027 for other micro and small operators
European Commission EUDR overview
The EU operator carries the regulatory due-diligence obligation, but a South African supplier may be asked to provide origin, production and geolocation information supporting that process.
The exporter should understand whether the product or any important input falls within the relevant scope. Where it does, records may need to connect the exported product with the relevant production area, supplier and production period.
Traceability should be designed into purchasing and production rather than reconstructed after the buyer requests it. Records can include supplier details, batch information, product origin and supporting declarations.
Review packaging entering international markets
Packaging requirements are also changing. The EU Packaging and Packaging Waste Regulation entered into force on 11 February 2025 and generally applies from 12 August 2026. It covers packaging and packaging waste and introduces measures relating to recyclability, material use, unnecessary packaging and reuse. European Commission packaging overview
South African exporters should confirm the packaging specifications required by the importer and destination market. This review can cover:
- Packaging materials
- Product-to-packaging ratio
- Recyclability
- Restricted substances
- Labelling and information
- Recycled-content requirements
- Transport protection
- Reuse or recovery arrangements
Packaging cannot be assessed only on the amount of material used. It must continue protecting the product through handling, storage and international transport.
The exporter should test changes before introducing them broadly. Reducing packaging is not an improvement if it leads to increased product damage or waste.
Address labour and human-rights expectations
Large international buyers may conduct due diligence across their supply chains and request information from direct and indirect suppliers. These requests can cover workplace safety, working hours, grievance procedures, forced labour, child labour, subcontracting and ethical conduct.
An exporter should be able to identify who manufactures the product and whether other facilities or subcontractors are involved.
A practical supplier record may contain:
- Legal entity and facility information
- Workplace and safety policies
- Employee grievance procedures
- Subcontractor disclosure
- Relevant inspections or assessments
- Corrective actions and completion dates
- Acknowledgement of the buyer’s supplier code
Documentation should reflect actual practice. Policies copied from another organisation or unsupported declarations may create commercial and reputational risk.
When a concern is identified, the response should be proportionate to its seriousness. Corrective action may be appropriate in some circumstances, while severe or repeated failures may require the supplier relationship to be reconsidered.
Use evidence rather than broad claims
Terms such as “green”, “ethical” and “sustainable” can be interpreted in different ways. Exporters should avoid broad claims that cannot be supported.
A stronger approach is to make specific statements, such as:
- The packaging contains a stated percentage of recycled material
- The product was manufactured at an identified facility
- The relevant batch can be traced to its supplier
- Packaging weight was reduced by a measured amount
- A particular standard or certification applies to the named facility
Certifications can support buyer confidence, but they should be checked carefully. The certificate must be valid and relevant to the product, organisation or production site being presented.
Businesses should also distinguish between verified results, supplier-provided information and internal targets.
Collect data in a repeatable way
Sustainability questionnaires can become burdensome when every buyer requests information in a different format. Maintaining a central evidence file can make the response process more manageable.
The file may include:
- Product and facility specifications
- Material and ingredient information
- Supplier declarations
- Packaging data
- Energy or emissions records
- Waste information
- Workplace policies
- Audit or inspection records
- Certifications and expiry dates
- Corrective-action records
Each document should have an owner and review date. Outdated information should not be reused automatically for future orders.
Where data is estimated, the calculation method and assumptions should be retained. This allows the exporter to update the figure consistently and explain how it was produced.
Prioritise the requirements that matter most
Small and medium-sized exporters may not have the resources to develop a comprehensive sustainability-management system immediately. A risk-based approach allows the business to start where commercial exposure is greatest.
Priority can be given to:
- Legal requirements affecting current target markets
- Questions from important existing buyers
- Products with higher environmental or social risk
- Information that is difficult to obtain later
- Improvements that also reduce cost or supply risk
For example, improving carton utilisation may reduce packaging and freight costs simultaneously. Better supplier traceability can support sustainability requirements while also improving quality investigations and product recalls.
Turn readiness into export competitiveness
Sustainability requirements can create additional work, but they can also distinguish suppliers able to provide accurate information and consistent evidence.
An exporter that responds quickly to buyer questionnaires, maintains traceability and understands destination requirements may be easier to approve and retain. This is especially valuable where international buyers are under pressure to improve visibility across their own supply chains.
The business should not make investments based on assumptions about what a market might require. Improvements should be connected to defined customer, product and regulatory needs.
Building a structured sustainability response
Global sustainability requirements do not apply uniformly to every exporter. Their effect depends on the product, destination, buyer and position within the supply chain.
GANS South Africa supports clients with product sourcing, supplier coordination and export preparation. GANS can assist with gathering product and supplier information, coordinating documentation and aligning supply arrangements with defined buyer requirements.
Legal interpretation, emissions verification and formal certification should be completed by appropriately qualified specialists. The role of the exporter and supply partner is to ensure that accurate information is available and that commercial orders reflect the requirements of the destination market.
A structured approach helps South African exporters respond more confidently as sustainability becomes increasingly connected to international purchasing and trade.
* This report provides general commercial information as at 10 August 2026 and is not legal, tax or certification advice. Regulations, product scope and implementation guidance may change. Exporters should confirm current requirements for the specific product and destination before shipment.
